VANA calls for a clear framework for producer fees in draft for a bill
VANA has submitted a consultation response to the draft amendment to the Environmental Protection Act regarding the maximum size of fees and the municipalities' phasing of costs under the extended producer responsibility for packaging.
VANA supports the intention of a model that promotes cost-effective operation and greater uniformity in municipalities' cost levels. At the same time, VANA points to a number of issues that should be clarified and adjusted to ensure more predictable and stable conditions for businesses.
VANA stresses that predictable and stable packaging prices are crucial for companies' ability to plan and budget, and therefore urges that the legislation and the forthcoming statutory order create greater transparency and more robust frameworks.
VANA's main points
- VANA highlights that the bill, despite political intentions of economic relief, in practice risks leading to increased costs for the business sector.
- VANA calls for clarity on how any subsequent payment should be allocated, and for a more representative allocation model that better takes into account actual collection and producer responsibility organisations' current quantities.
- Finally, the need is highlighted for more consistent and timely publication of producer fees, preferably through a central solution at The Danish Environmental Protection Agency or the Danish Utility Regulator.
We want simple and transparent frameworks for all the companies that are covered by the producer responsibility. It also applies to us producer responsibility organisations (PRO's). The current allocation of the municipalities' household waste to PRO's is very fragmented, and therefore requires extensive coordination and increases the risk of errors and delays. At VANA, we encourage that allocations in future are made according to a method that to a much greater extent groups municipalities into a single PRO, and that the allocations take account of quantities that during the allocation period move from one PRO to another.
CEO